The staffing processes of long term care facilities are about to get much more complicated. In accordance with Section 6106 of the Affordable Care Act, the Centers for Medicare and Medicaid (CMS) will be requiring such facilities to submit detailed staffing information electronically. This Payroll Based Journal Reporting (PBJ) is designed to promote accountability and consistency in reporting throughout the industry.
As of October 1, 2015, the CMS has been accepting information from facilities on a voluntary basis. Effective July 1, 2016, such reporting becomes mandatory. All long term care facilities must begin collecting staffing information to be reported through the CMS system with a due date of no later than November 14, 2016.
The CMS combines this detailed staffing data with the census data from each facility, and will use it in the Nursing Home Five-Star Quality Rating System to help consumers understand the level and differences of staffing in nursing homes.
What can long term care facilities do to prepare for the Payroll Based Journal Reporting requirements?
Register with the CMS –
Submission of staffing information through PBJ will be accessed through the Quality Improvement and Evaluation System (QIES). To connect to PBJ, each facility must have a CMSnet user ID. Details for registration can be found at CMS.gov. Individuals need to register to submit data into the PBJ system.
Identify and classify all direct care staff -
Direct care staff is defined as those individuals who, through interpersonal contact with residents or resident care management, provide care and services to allow residents to attain or maintain the highest practicable physical, mental and psychological well-being. For these individuals, the facility must submit to the CMS complete and accurate direct care staffing information that includes the following:
The category of work performed by each person on direct care staff including, but not limited to, Registered Nurse, Licensed Practical Nurse, etc. (a complete list can be found in the Electronic Staffing Data Submission Payroll-Based Journal Long Term Care Facility Policy Manual).
- Distinguish employees from agency (temporary) and contract staff
- The number of hours worked by each employee in each category of work each day
- Hire date
- Termination date
- Unique employee ID number
Maintain accurate census information –
Be ready to report the information with numbers effective on the last day of each month of the quarter.
Determine your method of data submission –
The PBJ system has been designed to accept two primary submission methods: manual data entry or uploaded data from an automated time and attendance system (XML format only). In addition, you can use both methods or combinations of these methods, for submitting as needed or desired.
The first mandatory reporting period starts on July 1, 2016 and will run through September 30, 2016. All PBJ data for this period will be due to the CMS by November 14, 2016. Providers can submit data as frequently as they like, with the minimum frequency being quarterly.
The last accepted submission before the deadline will be considered the facility’s final submission. The submission of this data needs to be timely and accurate. In addition, the CMS requires that the information be auditable so they can spot check the data as needed.
For these reasons, long term care facilities should consider implementing an automated time and attendance system that will add in timely reporting, increase accuracy and provide a reliable audit trail for this type of data.
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